Slavkin and Robins Quoted on CMS Enforcement and Pharmacy Benefit Managers

Consultants and attorneys are warning people that Medicare Part D’s “honeymoon period” is over as Year 2 starts and prosecution gets stricter. At the Financial Research Associates’ Medicare Operations and Compliance Summit in Alexandria, VA on July 17-18, Robert Slavkin, senior counsel in Foley’s Orlando office, advised attendees to build strong internal auditing procedures. He was quoted in the August 2007 issue of Medicare Part D Compliance News in the article, “Sponsors Must Prepare for CMS Audits, Enforcement, Consultants and Attorneys Say” as saying that within 18 months CMS will have a plan and their first target will be sales and marketing.

In the same issue of the newsletter, Lena Robins, senior counsel in the firm’s Washington, D.C. office, was quoted in the article, “Plans Shouldn’t Rely Solely on Their PBMs to Meet CMS FWA Compliance Plan Rules.” She was quoted as saying that PBMs need to be more transparent in data mining because of their large role in the Part D world.